For today's blog, we welcome guest blogger Terry Penney, a safety professional, presenter, motivational speaker, and safety program developer.
Even inspecting equipment is considered working on it.
A court has ruled that a maintenance electrician had “worked on” a stuck shipping door when he simply “inspected” it, even though he had not actually performed maintenance on it. He was injured when the door fell on him. The employer was found guilty of failing to ensure that the door was “blocked” before employees worked on it.
The maintenance employee testified that he “took a look at the controller [for the door] just to make sure, looked in to make sure that the P-L-C was powered up.” He agreed that he was “merely inspecting, trying to determine what the problem was.”
The trial justice found that “some level of work” took place and that the employer was therefore guilty of the offence of failing to ensure that the shipping door was blocked before it was “adjusted, repaired, or [had] work performed on it”—contrary to the Industrial Establishments regulation under the United States’ Occupational Health and Safety Act.
An appeal judge agreed and upheld the conviction. He stated that the Act doesn’t require that a “minimum or threshold amount of work be performed” before the Act’s requirements are triggered. The maintenance employee’s checks of the electrical system for the door amounted to “some work” and therefore the obligation to “block” the door had been triggered.
This case illustrates that workplace inspections aren’t just about a piece of paper, or a form, or finding errors on sites. Workplace inspections are ultimately about employers having a duty to protect the health and safety of any person in their employ or to whom they provide access to the workplaces they are responsible for.
What’s Involved in Workplace Inspections
Whether formal or informal, workplace inspections are regular examinations of workplaces to recognize and evaluate existing and potential hazards and recommend corrective actions. The process involves carefully examining work stations on a regular basis with a view to:
- identifying and recording actual and potential hazards posed by buildings, equipment, the environment, processes, practices, etc.
- recording any hazards requiring immediate attention
- determining whether existing hazard controls are adequate and operational
- recommending corrective action where appropriate.
A workplace inspection program includes several types of inspections:
- Spot inspections are carried out on occasion to meet a range of responsibilities with respect to workplace health and safety. They focus on a specific hazard associated with a specific work station or work area (e.g., noise made by a shredder, operation of a pump, pressure from a boiler, exposure to a solvent).
- Pre-operation inspections of special equipment and processes are often required before starting the inspection itself, such as equipment checks before working under water or entering a closed area.
- Critical parts inspections are regular inspections of the critical parts of a machine, piece of equipment, or system that have a high potential for serious accidents. These inspections are often part of a preventive maintenance program or hazard control program. Inspection checklists can be used for forklifts, tractor semi-trailers, and aircraft, for example.
- New equipment inspections involve a series of specific tests and checks that are carried out before starting up any new piece of equipment. For example, prior to starting to operate a recently acquired air compressor, the manufacturer or installer checks to ensure that all the parts are in the right place and are working properly.
- Routine inspections are inspections carried out on a regular basis in a given work area. They cover all working conditions, including work hazards, processes, and practices.
As with any other aspect of a prevention program, it’s important for senior management to demonstrate its commitment to workplace inspections and the goals they are intended to achieve.
How to Develop an Effective Workplace Inspection Program
There are four fundamental aspects of a good workplace inspection program:
- planning the actions to be taken
- physical inspection of premises
- writing an inspection report
- following up on recommendations.
In your planning, develop specific procedures identifying:
- the frequency of inspections
- the workplaces requiring inspection
- responsibility for conducting inspections, reviewing recommendations, and implementing corrective measures
- the qualifications of the individuals who will be carrying out the inspections; these people should have the necessary experience, training, and knowledge of the work stations and operations involved.
To determine how often workplace inspections need to be conducted—daily, weekly, monthly, annually, etc.—you need to determine what is necessary to ensure the recognition, evaluation, and control of workplace hazards. Reviewing the following may assist in that determination:
- the industry involved
- the kinds of work carried out
- the risks and hazards involved in the work and in the environment, including ergonomic risks
- the number of different work areas
- the number of workers in each work area
- the hours of operation
- the pace of the work
- other factors that are reasonable to include.
You should develop a written workplace inspection policy. The form and content of this policy can vary according to your business's requirements, but the following are all points to be considered:
- senior management's commitment to inspections and recognition of their importance
- the role of inspections in carrying out the general aims of the company with respect to workplace health and safety
- the designation of individuals who will be responsible for ensuring the proper operation of the inspection system
- measures required on the part of both the employer and employees to abide by the spirit and intent of the policy.
In conducting inspections, a basic principle should always be considered: Although they may need to ask questions, members of the inspection team should not unnecessarily interrupt the work of employees or in any way seek to assign blame for hazards. While it’s important to draw people's attention to any hazard that may exist, less important hazards can await the final report. There are "risk tables" that can be used to that end (e.g., CSA Z796-98).
After workplace inspections are conducted, the information obtained should be comprehensively analyzed to determine which areas are in need of general corrective measures and to identify trends as part of the effectiveness auditing program.
In particular, diligent analysis of inspection reports has the potential to:
- identify the need for training in certain areas
- explain why certain types of accidents occur in certain areas
- establish an order of priority for corrective action
- help to establish healthy work methods or improve existing methods
- identify areas, equipment, tasks, etc. for which a more in-depth risk analysis would be helpful.
Inspection information requirements include:
- basic layout plans showing equipment and materials used.
- process flow
- information on chemicals
- storage areas
- workforce size, shifts, and supervision
- workplace rules and regulations
- job procedures and safe work practices
- manufacturers’ specifications
- personal protective equipment (PPE)
- engineering controls
- emergency procedures (fire, first aid, and rescue)
- accident and investigation reports
- worker complaint reports regarding particular hazards in the workplace
- recommendations of the Joint Health and Safety Committee
- previous inspections
- maintenance reports, procedures, and schedules
- regulator inspection reports or other external audits (e.g., insurance, corporate, specialist)
- monitoring reports (levels of chemicals, physical, or biological hazards)
- reports of unusual operating conditions
- names of inspection team members and any technical experts.